The Five Misunderstandings of Regulated Social Media

By Peter Pitts –

The use of social media by regulated industry is faltering because of fear, timidity, and misunderstanding.

I’d like to make five main points that are often overlooked or misconstrued when we discuss social media in the context of regulated speech:

1. There is a difference between online advertising and social media

When the FDA sent out the “famous 14” warning letters about sponsored Google links, many pharmaceutical regulatory review professionals said, “See, told ya – you can’t use social media,” and breathed a secret sigh of relief – another sign of an ever-growing regulatory Stockholm Syndrome.

But they were wrong, because when you read the letters it becomes quickly evident that the FDA’s Division of Drug Marketing, Advertising, and Communication equates “sponsored links” not with social media – but with paid advertising. In the context of those letters, “sponsored” equals “paid.” And there are rules for that.

Beware, because as Disraeli said, “A precedent embalms a principle.”
2. There is a difference between social media platforms and social media content

The FDA sent out a warning letter regarding a YouTube video in which a paid celebrity spokesperson said that a drug had “cured” her disease (a decidedly off-label claim, shades of Dorothy Hamill and Vioxx). And some internal reviewers industry-wide said, “See, you can’t use YouTube.” Not so. If the content is non-compliant, then it is non-compliant regardless of platform. On the positive side, I believe the reverse is also true.

Division of Drug Marketing, Advertising, and Communication Director Tom Abrams has made it clear that when there is guidance from the agency on social media, it will not include agency direction on how to use specific platforms such as YouTube or Facebook or Twitter – and that includes emerging mobile platforms too.

3. The fear of adverse event discovery is dangerous and misguided

As recently as last November, one large pharmaceutical company told me that its official policy was not to monitor social media sites for fear of unearthing adverse events. This would not play well in a newspaper story or in front of a Congressional subcommittee.

Industry’s regular and public social media “AE-phobia” only reinforces the public’s erroneous notion that industry communications are solely about money and marketing – and the public health be damned. Social media abhors a vacuum. In 2011 we must embrace and rejoice in social media’s capability to unearth adverse experiences early and often. Quod erat demonstrandum.

4. The fear of user-generated content and off-label conversations is real … but

There are many solutions, ranging from moderating comments (which are generally accepted by social media communities as long as they understand the necessity for such moderation) to corporate responses directing the user to a given product’s PI and pre-vetted company web pages.

But these tactical solutions don’t solve or even begin to address the issue of “property owner” vs. “property user,” an issue that was mentioned by the FDA in its Federal Register notice for its November 2009 Part 15 hearing.

That’s an issue that the FDA would be wise to address in its forthcoming guidance to industry.

5. Who’s responsible for what?

Social media is a big place. Can any single company be held responsible for what’s said about itself or its products anywhere online? Consider the current on-the-books guidance, which reads, “Applicants should review any internet site sponsored by them for adverse experience information, but are not responsible for reviewing any internet sites that are not sponsored by them.”

But what does “sponsored” mean?

Consider the oft-heard TV voice-over, “This portion of the Masters is sponsored by (name of erectile dysfunction product). Nobody in the viewing audience thinks the sponsor chose the speed of the greens or the pairing of the golfers, or the height of the rough. But say “sponsored” on interactive social media and watch the sparks fly at internal regulatory review.

Abrams has said that FDA guidance will address corporate responsibility for correcting and monitoring third-party sites for misinformation. It would be very useful for Abrams’ division to also clarify, among other things, what “sponsored” means.

Let me be blunt – expecting a regulatory holy grail will only lead to disappointment and frustration. And blaming the FDA when that happens won’t make anything better or move the social media agenda ahead any further or faster. Social media is the new frontier. It is the crucial grade that exists between regulated speech and user generated content. In the 21st century, it is where the public health rubber meets the communications road.

Social media requires interactive engagement in real time. It requires you to play rather than purchase. And that’s a wonderful opportunity – because you cannot purchase passion.

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Tackling the Facebook zombies

Anthony Lowe – 27 May 2011 – Porter Novelli –

Heard that Facebook is a great site to build a community for your brand? Read the stories of brands setting up a new Facebook page for their latest products and 150 people liked it? Or even, you liked a Facebook page last year but haven’t heard anything from it in a while?

Then you have experienced the outbreak of zombie groups on Facebook. Or in non-digital lingo, Facebook pages that have been left untended like the ghost towns of old (minus the tumbleweeds).

Zombies aside, the use of Facebook to form a community is a well-proven social media tactic. With 550 million plus members and a very active Australian audience, Facebook is currently the best platform to build an active community around a topic, product or brand. But active is the key word.

Without activity, the engagement of the page audience becomes sporadic, the effort required to stimulate interest increases and becomes harder to sustain, the return on investment is unclear, the marketing budget gets reallocated and the page quickly joins the growing numbers of virtual zombie groups.

So before setting up a page on Facebook, take a medium-term outlook with your plans. We recommend looking at the following five considerations to get the best return:

1. Allow time to attract a solid community. Don’t be in a rush to deliver an ROI – sometimes building an audience with the right members can take months.

2. Consider the resourcing required to keep the community active. Share the workload and ensure you have a content pipeline in place to keep the audience engaged over the medium term.

3. Be interactive. Respond to comments, ask questions, listen to what your community is looking for and give it to them.

4. Focus evaluation on outcomes not outputs. Outputs are Friends or Likes on Facebook. Outcomes are getting the audience to do something like share ideas, attend an event, recommend your brand to friends, or simply buy the product. And remember to determine what success is, before you start.

5. If the product campaign is over, manage your exit appropriately. Tell your audience why you are closing the page. If a new campaign is starting, tell them about it so before you shut down your page they have the option to move across.

Whatever you do, don’t let your brand page join the zombies – it can still be found in searches. Shutting it down is just a simple mouse click – no need to whack it with a shovel.

How marketing bosses should Tweet

Willem Smit

Published 7:32 AM, 19 Apr 2011 – Business Spectator


Twitter users now send more than 140 million Tweets a day. With more than 20 per cent of the tweets being related to products and/or brands, this means that every day 28 million tweets potentially concern your brand or company. The micro-blogging sphere has undeniably become a worthwhile place for listening to customers and potentially influencing perceptions, attitudes and behaviours by engaging into their conversations.

The relevant question has therefore moved from if marketers should get involved to how they should deal with it. Not only Twitter, but social media, in general, poses novel challenges to brand building and management. Basically, it comes down to the fact that control is handed over to consumers. The times in which the firm controls what the brand stands for are gone. Consumers own the brand. Having lost control, today’s competition necessitates that brands learn to respond more quickly. It would make sense that marketers keep their own fingers on the pulse of a dynamic and vast media space like Twitter, and follow sound marketing advice: listen, listen, listen! Doing so enables marketers to learn first-hand about what customers are saying about brands and competitors. Yet, is there something else that can be done? If so, what should be done?

What are CMOs [Chief Marketing Officers] of the leading brands doing? As Twitter recently celebrated its fifth birthday, have they joined in the celebrations? Are they even on Twitter? If so, how often do they tweet? And what do they tweet? We systematically examined CMO’s Twitter presence of Interbrand’s 25 most valuable global brands. Of the top 25, 17 brands have assigned a CMO. Only half of them have a clearly identifiable Twitter account.

Very different Twitter styles

It seems that the nine top brand CMOs active on Twitter have not found one single right answer. They have very different tweeting styles. On one extreme of the spectrum are Joseph Tripodi from the world’s largest brand Coca Cola, Lorraine Twohill from Google, Jerri DeVard from Nokia and Marc Pritchard from P&G. They have an account, but have not tweeted and as a consequence their number of followers is limited. It could be that they only use it for listening.

On the opposite end of the spectrum we find CMOs with a more active style, like IBM’s Jon Iwata, GE’s Beth Comstock and HP’s brand-new CMO Bill Wohl. Jon’s tweets come in waves. Days pass without a tweet from him, and then there are four to five days a months on which he sends out larger numbers of messages. The topics of all his tweets are IBM-related: announcements about the opening of an IBM branch, strategic priorities and investor briefings.

More regular and frequent are @bethcomstock and @bill_wohlHP’s tweeting behaviours. Beth is GE’s longtime CMO and she regularly shares her experiences about events and customer visits. Bill was recently appointed to the position after he joined from SAP. He immediately took it on himself to start tweeting and in fact has done so 20 times in the last 15 days. His content is a mix of company press releases and personal experiences.

Even more personal and experimental is Barry Judge from US retailer Best Buy (@BestBuyCMO, ). Barry sends two / three tweets every day mixing work with play. A striking example is: “Trying this to see what happens. I have a room at Little Nell’s in Aspen from Mar 23-27. I can’t go. Anyone know how I can find a renter?”

Your own voice on Twitter

Within this spectrum, it is key to find your own voice. It is important to determine what style is appropriate for you and your brand. There are a couple of issues needed to take into consideration. A more active tweeting style has both benefits and drawbacks. It is up to you to weigh them.

Benefits of active tweeting are informational and reputation building:·

  • Quicker speed in customer sensing – Twitter is one of the fastest ways to identify what is happening with your brand
  • Less dependent on internal customer insight sources. Having your own direct channel of information disciplines the insights that company channels provide you with.
  • · More approachable – opening a Twitter account gives external audiences the possibility to contact you instantly. At least it shows that you and your brand are open for feedback and sends a signal that you personally care.

Drawbacks of active tweeting are time-consuming, distraction and confusion:

  • · More distraction – the content of many tweets, according to research firm Pear Analytics, is 40% filled with pointless babble, plus much of it is conversational and self-promotion. If “lists” are not carefully designed and “Whom-to-follow” is not well done, it is difficult to filter what is important. Then tweeting creates a lot of useless distraction.
  •  More confusion – personal branding can get confused with company branding. : It is dangerous to post a disclaimer that says: “what I post here is really my opinion, and not necessarily the opinion of my company”

If you do not want to make this trade-off, is it still an option to just open a Twitter account and then only listen? No, not really, because remaining a wallflower may violate a critical communication law formulated by Austrian-American psychologist and philosopher Paul Watzlawick who claimed that: “no one cannot communicate.” Meaning that staying silent on Twitter also sends a signal. A signal of silent presence may well be interpreted as ambiguous and could easily be explained as being “uninterested”, “too busy with other things than with customers”, or even “arrogant.” It is up to you, and your company to weigh the pros and cons of a more active Twitter style.

Willem Smit is a Research Fellow at IMD, the leading global business school based in Lausanne, Switzerland. He can be followed on Twitter at @WillemSmit.